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A period of “leniency” in IRS enforcement of international withholding requirements must come to an end with changes in the regulatory environment, says Michael Danilack, deputy commissioner (international) in the Large and Mid-Sized Business Division. Danilack says that while the passage of the Foreign Account Tax Compliance Act has gotten attention as “the latest, hottest new area in withhholding,” longstanding compliance issues remain in other international withholding areas. He urges practitioners not to lose sight of the existing tax code Chapter 3 withholding issues even as FATCA adds a Chapter 4, noting that FATCA implementation is still two to five years away.
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